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Recenly I got to talk with Max Aulakh of Ignyte Assurance Platform. The topic was CMMC, CUI, and FedRAMP, three acronyms that show up in almost every conversation I have with a manufacturer these days, and that almost nobody feels fully confident about. That includes me, some days.
We had more questions than time. That happens when a topic is this tangled and this important. So this post answers the ones that came up on the call, in the chat, and in the months of customer conversations that led us to host the webinar in the first place.
A note on how to read this. Some of these answers come from Max. He is the accredited assessor who has been auditing Cableteque, and where the answer is his, I say so. Where it is mine, I have tried to be specific about what we have done, what we have not done yet, and when. Nothing here is legal advice, and no software vendor, including us, can make a compliance determination on your behalf. That determination is always yours and your counsel's to make.
They govern different things.
CMMC is a corporate certification. It is linked to your company, specifically your CAGE code, and verifies that your organization is properly protecting Controlled Unclassified Information (CUI). If you are a Tier 1, 2, or 3 supplier working with a prime or directly with the government, this is the one that applies to you.
FedRAMP applies to cloud products. When you use a cloud service that will touch CUI, that service has to meet its own bar. Max put it well on the call: CMMC has roughly 110 requirements; FedRAMP has more than 300. The barrier to entry for cloud providers is considerably higher.
Both trace back to the same underlying question. Is CUI being protected? They are just two different mechanisms for answering it, each aimed at a different party.
You need CMMC. Your cloud vendor needs FedRAMP authorization or Moderate Equivalency.
This is the single most common point of confusion I run into, and it costs people time. Manufacturers routinely ask us whether Cableteque is "CMMC certified." It's the wrong question to ask a cloud provider. CMMC is a certification for organizations in the defense industrial base, not for the software they buy. The right question is whether the cloud service meets the FedRAMP Moderate bar, because that's what permits CUI to be processed in it under DFARS.
It's the Defense Federal Acquisition Regulation Supplement clause covering safeguarding of covered defense information and cyber incident reporting. In practice, it's the clause primes flow down to their suppliers, and it's the reason cloud vendors get pulled into your compliance perimeter at all.
Max's framing on the call has stuck with me: the clause is fundamentally about having solid cyber practices and a real incident response capability. The frameworks- FedRAMP for cloud products, CMMC, and NIST 800-171 for everyone else- are how you demonstrate you're actually meeting it. Frameworks get revised over time. The underlying rule is much harder to change.
It's the underlying set of security requirements that CMMC verifies. There's roughly a 90 percent overlap between the two. A completed NIST 800-171 self-assessment is meaningful work toward CMMC. It isn't the same thing as certification, but it isn't wasted either.
The phased rollout, specifically the requirement to obtain a third-party assessment as a condition of contract award, during the review period.
Essentially everything underneath it. DFARS 252.204-7012 still applies. NIST SP 800-171 still applies. Self-assessments, SPRS scores, and annual affirmations still apply. Government audits continue.
Max was direct about this on the call. Many executives read the headline as "CMMC is going away." It isn't. The requirement originates in legislation that passed Congress, which is very hard to undo. Treat it as a pause for adjustment, not a cancellation.
Ignyte's position, and they're the ones running these assessments, is no. They're still conducting CMMC assessments and submitting them to the government today. If you've already invested, that investment holds. The most likely outcome of the review is some interpretation that's more workable for small businesses, not the disappearance of the obligation.
Yes, and this was one of the more striking data points from the call. Max described a contract vehicle tied to the Golden Dome program that asked, via a deliverable line item, which bidders were CMMC-certified. More than a thousand companies applied. Four or five actually held the certificate.
The pattern he described: established tier 1 suppliers use certification as a discriminator and are telling the government their supply chain is clean. Emerging defense companies care but prioritize speed, slowing their burn rather than stopping. Almost nobody stops entirely.
Honestly, no, and Max said so plainly on the call. One of the genuine weaknesses of the current programs is that the controls were separated from clear data-labeling guidance. Anyone offering you a crisp universal rule is overselling.
Here's how experienced assessors actually reason about it instead.
Not automatically. The distinction turns on whether the government co-created the capability.
Max's analogy is the clearest I've heard on this. Suppose you build a commercial boat that does a thousand miles an hour, entirely on your own dollar. The government hands you a specification asking for something that does five hundred. Even though their requirement is less capable than your commercial product, the specification they gave you reflects a government capability need, so it, and the parts tied to it, are likely CUI. Your faster commercial version isn't necessarily.
Where the government funded or co-developed the capability, the output is generally treated as CUI. Where you built it privately, you have a stronger argument that it's your intellectual property.
Individual commercial parts generally aren't the issue. The assembly is.
Max described working with a large publicly traded manufacturer that got a formal legal opinion on exactly this. They source thousands of parts that anyone can buy, but the recipe, how it all goes together, is what makes it CUI. His caveat mattered: that position is defensible as long as you have counsel who will stand behind it.
There's also a lighter category worth knowing. A basic bill of materials may fall under FCI, Federal Contract Information, rather than CUI, which is protected at CMMC Level 1, a substantially lighter requirement, if you can justify that the BOM is genuinely just a parts order.
This is the most common practical problem among our customers, and it deserves a real answer rather than a shrug. Markings in this space are genuinely inconsistent. Legacy distribution markings and STINFO markings are still circulating, and the DoD classification program for CUI is not fully built out the way it is for Secret and Top Secret.
Four steps hold up in practice:
It's an understandable instinct, and for some shops it's the right call. But it isn't automatically the conservative choice, and it isn't free.
Max's practical framing has stayed with me: if you're doing sheet metal work or anodizing screws, it isn't marked, and you sell the identical part commercially, there's limited value in spending money to protect something already publicly available. A boundary drawn too wide costs more to build, more to evidence, and can be harder to actually defend.
The shops we see carrying the widest boundaries are usually the ones who never asked their customer the question above.
They're separate regimes that frequently overlap, and conflating them causes real confusion.
CUI is the newer data-handling framework. ITAR is roughly 10 to 15 years older and is specifically rooted in defense articles and weapons systems, and is administered by the Department of State. Where only a physical defense article is involved, ITAR is usually clear-cut. It gets murky as soon as technology and software enter the picture.
Export-controlled information is one of the categories listed in the CUI registry at dodcui.mil, a useful public reference. So the two frequently coincide, but not all CUI is export-controlled, and ITAR obligations can exist entirely outside a government contract.
I'll share something from my own experience. When I sold my previous wire harness company, we went through a CFIUS review. Despite the business being 100 percent defense-related, only two relatively small programs were ITAR-controlled. Everything else was CUI. The assumption that defense work equals ITAR work is often wrong, and I found that out the hard way, at the worst possible time to find out.
Per Max, the customer placing the order carries that responsibility, because the government is ultimately supposed to identify it. That said, the classification infrastructure for CUI and export-controlled data isn't as mature as it is for classified information, so in practice the answer often has to be pursued rather than received.
Ignyte's working approach for technology-enabled companies is to take the conservative position and confirm through analysis rather than assume. This is a legal determination. If you believe you may hold ITAR-controlled technical data, that conversation belongs with your export-control counsel or your Empowered Official, not with a software vendor.
CabletequeGov is a separate, U.S.-hosted environment built for sensitive technical data, with access restricted inside the boundary. Customers doing defense work generally run there rather than on our commercial instance.
What we won't do is tell you whether your data is ITAR-controlled, or represent that using our platform satisfies your export-control obligations. Those determinations sit with you and your counsel. What we can do is accurately describe our environment, in as much detail as your compliance and export teams need, and support them directly.
On July 27, 2026, CabletequeGov was approved as FedRAMP Ready and listed on the FedRAMP Marketplace, ID FR2620331565.
The readiness assessment was conducted by Ignyte against the FedRAMP Moderate baseline, covering the full system boundary, infrastructure, platform, and application. The FedRAMP Program Management Office reviewed the results and identified no concerns.
Max's explanation on the call is the one you should carry with you. FedRAMP Ready is designed to answer the question: forget the paperwork, are you actually protecting the information, and are you hosted in the right place? It reflects that substantive technical controls are implemented: FIPS-validated encryption, an active vulnerability management program with real scans in progress, source code analysis, and hosting on appropriate U.S. infrastructure.
What it is not: FedRAMP Ready is not a FedRAMP authorization, nor is it the same as a completed Moderate Equivalency. I want to be unambiguous about that, because your assessor will be. Some customers will accept it as evidence of a serious, independently validated trajectory. Others will want the completed package before placing CUI in any external cloud. Both positions are legitimate, and we support customers taking either one.
Ready reflects that the technical controls are in place and have been independently observed. Equivalency is the full assessment against the complete Moderate baseline, with the accompanying documented body of evidence a CMMC assessor will want to see.
As Max put it: the hard technical work is substantially done. The remaining work is to complete the full audit and the accompanying documentation.
We expect to complete the full FedRAMP Moderate Equivalency audit with Ignyte in November 2026. We'll notify customers directly when the body of evidence is available.
Available now, on request and under NDA where appropriate:
The full 3PAO-validated body of evidence will be made available upon completion of the equivalency audit, and we'll make it available under NDA at that point.
Yes. This is one of the most useful things we can offer, and I'd rather do it early than late. Our security team will engage your assessors directly and answer their questions.
Ignyte also offered something valuable on the call. If you're working with your own assessor and want a second opinion, they're glad to share precedent, what the government has accepted in comparable environments, and why. The most common complaints they hear are that assessors over-interpret a requirement or don't understand manufacturing well enough to translate a control into practice. An outside perspective often unblocks both.
It matters, and it's worth confirming rather than assuming. Any work involving CUI belongs on CabletequeGov. If you're unsure which environment your account is provisioned in, ask us. We'll confirm it in writing, and we'll move you if you're in the wrong place.
Worth knowing: our commercial and gov platforms share the same underlying architecture, tooling, and security controls. We're a focused company, and we don't maintain two different security postures. The differences are in where each is deployed and how technical data is handled, which means the work we've done for defense customers benefits our commercial customers too.
We ran short of time for this on the call. It generates more questions than any other topic among our customers, so I want to answer it properly here.
No. Not ours, and not any third party's. This prohibition is contractually binding on every AI provider we use, not just a statement of policy.
No. AI features are opt-in and disabled by default. Enabling them requires a signed feature release from the customer, and all outputs are designed for qualified human review.
I'll be honest, this creates friction. Customers occasionally discover the gate during a training session. We've kept it anyway, because a control you can't accidentally bypass is worth the inconvenience.
All AI processing for the gov environment occurs within approved U.S.-region environments, with providers documented in our system architecture and within our assessment scope. We'll share the specific subprocessor list and the data flow with your compliance team on request.
Yes, architecturally, not just contractually. Your designs, part data, and commercial terms are isolated to your account.
Largely, no, and this is worth understanding, because it means "we're FedRAMP aligned" is not by itself an answer to an AI question.
The established frameworks were written before generative AI was a mainstream part of engineering workflows. Newer standards are emerging, ISO/IEC 42001 and the NIST AI Risk Management Framework among them, but they aren't yet what a CMMC assessor is checking against. In our own program, Ignyte developed a mapping between NIST 800-53 controls and AI-specific security requirements to deliberately address that gap rather than assume it away.
A practical checklist, useful regardless of whether you ever work with us:
Yes, and it's worth being straightforward about it. Model availability in authorized government regions lags commercial availability. The newest models are frequently not yet authorized for these environments. That's an industry-wide constraint rather than a Cableteque one, but it's real, and any vendor telling you otherwise deserves a follow-up question.
In the next 30 days: identify where FCI and CUI enter your business. Map the systems and vendors that touch it. Review your contract flowdowns. Confirm your NIST 800-171 self-assessment posture. Ask your cloud vendors for their actual status and the evidence behind it.
In the next 60 days: define or tighten your CUI boundary. Remove applications and external data flows that aren't needed. Build or update your SSP and POA&M. Decide whether customer pressure justifies a third-party assessment now.
In the next 90 days: close material technical gaps. Test your incident response. Validate your vendors' responsibility matrices. Choose your path based on your contracts and revenue, not on fear.
In most shops, this lands on a quoting manager or operations lead who didn't ask for it. That works for the first 30 days of discovery, but the decisions that follow are contractual and financial. Get an executive sponsor early, and make sure whoever owns the contract review is in the room. Most of the answers you need are in your own contracts.
Three things we're happy to do, none of which require you to be a customer:
Reach us at security@cableteque.com, or through your account contact.
This post is provided for general information and does not constitute legal, export-control, or compliance advice. Compliance determinations, including whether specific information is CUI or export-controlled, rest with the organization holding the data and its counsel. FedRAMP® is a registered mark of the U.S. General Services Administration. Reference to FedRAMP status does not imply endorsement by the U.S. Government.
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